Sam Bear

Tax Litigation. Sam’s experience includes the litigation, trial, and appeal of major corporate and partnership cases involving hundreds of millions or billions of dollars in tax liability. Her work spans all stages of litigation—from resolving discovery disputes to supporting witness presentation at trial to preparing other advocates for appellate oral arguments—in a range of venues. She has represented taxpayers in front of the Tax Court, district courts, and courts of appeals.

IRS Administrative Proceedings. Sam has represented clients in all stages of IRS examination and Appeals administrative proceedings. For clients under audit and in Appeals, Sam draws on her litigation experience to advise on techniques for responding to complex document requests and to anticipate and develop potential expert arguments.